Core Strategy Submission Document

RDC have not consulted on the very specific proposals to relocate the Eldon Way and Foundry Industrial Estates
ï‚· The previous CS Strategy stated "we will look at opportunities for more valuable and appropriate uses of the industrial land" with absolutely no consultation at all on concept of moving existing EW businesses entirely
ï‚· the Foundry Industrial Estate has never even been previously mentioned in any plan version; A recent amendment to the Core Strategy states this omission was due to a typing error!
ï‚· The Urban Capacity study stated a "low probability" of housing and did not even mention the Foundry Estate

Thus the proposals are they are not founded on a robust and credible evidence base and are unsound.

Eldon Way and Foundry Industrial Estates form a significant part of the ongoing Hockley Area Action Plan (HAAP) consultation but the Core Strategy proposals pre-empt the next stage of the HAAP consultation.

Neither the Core Strategy nor HAAP define its status relevant to the other plan and subsequent priorities. Why is there no cross-referencing between concurrent plans affecting the exact same piece of land?

There are also inconsistencies between the Core Strategy & HAAP regarding the description of proposed uses for the two industrial estates. The Core Strategy refers to Leisure, Commercial and Residential whilst HAAP mentions a "village green, introducing a significant area of public open space". There is not sufficient space for both and the Core Strategy is again pre-empting the ongoing HAAP.

If a decision is taken now, as part of the Core Strategy, to relocate all the existing businesses on the two estates, it will set a legal precedent which HAAP will need to follow and renders the next stage of HAAP virtually redundant. Particularly given the 95% rejection rate of respondents to the previous round of HAAP such an approach is entirely undemocratic and unsound.

Eldon Way and Foundry Industrial Estates form a significant part of the ongoing Hockley Area Action Plan (HAAP) consultation but the Core Strategy proposals pre-empt the next stage of the HAAP consultation.

Neither the Core Strategy nor HAAP define its status relevant to the other plan and subsequent priorities. Why is there no cross-referencing between concurrent plans affecting the exact same piece of land?

There are also inconsistencies between the Core Strategy & HAAP regarding the description of proposed uses for the two industrial estates. The Core Strategy refers to Leisure, Commercial and Residential whilst HAAP mentions a "village green, introducing a significant area of public open space". There is not sufficient space for both and the Core Strategy is again pre-empting the ongoing HAAP.

If a decision is taken now, as part of the Core Strategy, to relocate all the existing businesses on the two estates, it will set a legal precedent which HAAP will need to follow and renders the next stage of HAAP virtually redundant. Particularly given the 95% rejection rate of respondents to the previous round of HAAP such an approach is entirely undemocratic and unsound.

PPS12, 4.6, states that Cores Strategies should be flexible and "should be able to show how they will handle contingencies". Several large planning applications have already been submitted to RDC proposing developments outside the Core Strategy which does not indicate how such applications will be handled and does not comply with PPS12. Neither have RDC been able to advise residents how such changes will be made and the strategy is unsound.

THE Core Strategy misrepresents the findings of The Retail & Leisure Study (R&LS) 2008.

The Core Strategy states (12.38) "The Retail & Leisure Study indicates Hockley has great potential. Hockley has been identified as having a need for additional convenience floorspace".

Whereas, the R&LS actually states:
1) (10.26) "the scale of need does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure.
2) (10.28) "There is no immediate capacity for additional floor space."
3) (10.29 "we recommend that focus be maintained on developing Hockley's
existing strengths, rather than retail expansion"
4) 10.31 "The current nature of Hockley does not lend itself to classification as a 'town centre' as defined by PPS6. Moveover, we have identified that it is a very small catchment population. Accordingly, the Council may wish to consider reclassifying Hockley from a town centre to a district centre".
The Core Strategy is inaccurate, misleading and unsound.

THE Core Strategy misrepresents the findings of The Retail & Leisure Study (R&LS) 2008.

The Core Strategy states (12.38) "The Retail & Leisure Study indicates Hockley has great potential. Hockley has been identified as having a need for additional convenience floorspace".

Whereas, the R&LS actually states:
1) (10.26) "the scale of need does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure.
2) (10.28) "There is no immediate capacity for additional floor space."
3) (10.29 "we recommend that focus be maintained on developing Hockley's
existing strengths, rather than retail expansion"
4) 10.31 "The current nature of Hockley does not lend itself to classification as a 'town centre' as defined by PPS6. Moveover, we have identified that it is a very small catchment population. Accordingly, the Council may wish to consider reclassifying Hockley from a town centre to a district centre".
The Core Strategy is inaccurate, misleading and unsound.

Proposals for moving employment to out of town locations, at either end of the district, with no existing public transport links, are contrary to government policy PPG4. It also contravenes the Core Strategy's stated aims of reducing carbon emissions; reliance on car transport and providing "an integrated network of cycle paths".

The District of Rochford is predominately spread on a West/East axis along the railway line. Hockley is located in the middle of the district and the two estates are adjacent to the railway station. Bus services are poor with just 3* an hour (following a recent 50% reduction in services) and the operator has admitted they cannot compete with the railway making improvements to new sites away from major centres unlikely. (* one of the 3 services is paid for by ECC on a 6 mth trial and may be terminated in the new year).

However, the Core Strategy proposes to relocate these two estates to a greenfield site near the airport. This site is 2-3 miles from the nearest railway station and there are currently no bus services to the area. As a result, RDC are proposing to upgrade the nearest road to a dual-carriageway, although the main connecting road (the B1013), which runs through Hockley, will remain single-carriageway and is already at 72% of capacity (ECC Highways stats). This is despite extra traffic expected in the area as a result of the Joint Area Action Plan (JAAP) which proposes considerable growth at neighbouring Southend Airport, as well as the new industrial estate.

The site selected for the new industrial estate also contravenes PPS4 which states;
ï‚· (EC7.3C) "out-of-centre sites, with preference given to sites which are or will be well served by a choice of means of transport and which are close to the centre and have a high likelihood of forming links with the centre. There is no existing public transport and no obvious likelihood of forming links with any existing centres.
ï‚· EC7.5 1 "whether the site is or will be accessible and well served by a choice of means of transport, especially public transport, walking and cycling, as well as by car". Its remote location. Accessed by the narrow, busy B1013 is not suitable for access by cycle or on foot.

It also contravenes PPS1 (27 vii) "Reduce the need to travel and encourage accessible public transport provision to secure more sustainable patterns of transport development. Planning should actively manage patterns of urban growth to make the fullest use of public transport and focus development in existing centres and near to major public transport interchanges".

The Core Strategy also contravenes its own policy T1 and is unsound.

Previous consultations and public opinion ignored by RDC and HAAP pre-empted:
As well as ignoring the Parish Plan and the 95% rejection rate of the HAAP proposals, the Core Strategy proposals pre-empt the next round of the HAAP.

Public opinion in Hockley is strongly against both the HAAP and Core Strategy proposals for Hockley Village Centre. A survey undertaken in October 2009 had 972 responses (over 20% of households) and the key results were:
- shops: only 5% in favour of major redevelopment (43% supported moderate redevelopment and 52% only wanted minor improvements)
- Eldon Way & Foundry Industrial Estates: just 13% wanted major change with a youth centre suggested as the most popular improvement.
- Roads: nearly 2/3rds wanted to retain a roundabout at the Spa Junction instead of traffic lights proposed by RDC.

Thus the proposals are not founded on a robust and credible evidence base and are unsound.

Previous consultations and public opinion ignored by RDC and HAAP pre-empted:
As well as ignoring the Parish Plan and the 95% rejection rate of the HAAP proposals, the Core Strategy proposals pre-empt the next round of the HAAP.

Public opinion in Hockley is strongly against both the HAAP and Core Strategy proposals for Hockley Village Centre. A survey undertaken in October 2009 had 972 responses (over 20% of households) and the key results were:
- shops: only 5% in favour of major redevelopment (43% supported moderate redevelopment and 52% only wanted minor improvements)
- Eldon Way & Foundry Industrial Estates: just 13% wanted major change with a youth centre suggested as the most popular improvement.
- Roads: nearly 2/3rds wanted to retain a roundabout at the Spa Junction instead of traffic lights proposed by RDC.

Thus the proposals are not founded on a robust and credible evidence base and are unsound.

Previous consultations and public opinion ignored by RDC and HAAP pre-empted:
As well as ignoring the Parish Plan and the 95% rejection rate of the HAAP proposals, the Core Strategy proposals pre-empt the next round of the HAAP.

Public opinion in Hockley is strongly against both the HAAP and Core Strategy proposals for Hockley Village Centre. A survey undertaken in October 2009 had 972 responses (over 20% of households) and the key results were:
- shops: only 5% in favour of major redevelopment (43% supported moderate redevelopment and 52% only wanted minor improvements)
- Eldon Way & Foundry Industrial Estates: just 13% wanted major change with a youth centre suggested as the most popular improvement.
- Roads: nearly 2/3rds wanted to retain a roundabout at the Spa Junction instead of traffic lights proposed by RDC.

Thus the proposals are not founded on a robust and credible evidence base and are unsound.